Message-ID: <17938707.1075844566451.JavaMail.evans@thyme>
Date: Mon, 11 Sep 2000 07:07:00 -0700 (PDT)
From: sara.shackleton@enron.com
To: jeff.blumenthal@enron.com
Subject: Re: Instinet Corporation
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X-From: Sara Shackleton
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FYI
----- Forwarded by Sara Shackleton/HOU/ECT on 09/11/2000 02:06 PM -----

	Janine Juggins
	09/11/2000 02:42 AM
		
		 To: Stephen H Douglas/HOU/ECT@ECT
		 cc: Sara Shackleton/HOU/ECT@ECT, Jordan Mintz/HOU/ECT@ECT
		 Subject: Re: Instinet Corporation

Sara, 
we are currently working with John to establish a corporate structure for 
equities trading out of London. I am due to meet with him today or tomorrow 
so will follow up on these particular trades.
Regards
Janine


To: Sara Shackleton/HOU/ECT@ECT
cc: Janine Juggins/LON/ECT@ECT, Jordan Mintz/HOU/ECT@ECT 

Subject: Re: Instinet Corporation  

Thanks for being on top of this.  As I mentioned in my voice mail to you on 
Friday, no trader should conclude a transaction on behalf of ENA while 
located in a foreign country.  On several discrete occasions we have 
sanctioned exceptions to this rule but each such case had unique facts that 
permitted us to conclude that those transactions were OK.  Further, any 
physical presence by ENA is a foreign country is generally a bad idea because 
it supports a foreign tax authority's argument that ENA is doing business in 
their country.  Thus, because of that general concern, no Instinet terminal 
should be put in place on behalf of ENA in a foreign country (especially 
since for what purpose would such a thing be used - trading?) but, rather, an 
appropriate foreign affiliate of Enron should contract for such service (in 
this respect, you should speak with Janine Juggins in our London tax group - 
Janine is our resident trading tax expert in London and will be very familiar 
with the things described in this E-mail).  I will be out of the country this 
week (returning the week of the 18th) and can be reached at the Vancouver 
Hotel in Vancouver, British Columbia.  Best regards.  Steve.


From: Sara Shackleton on 09/08/2000 04:46 PM
To: John Greene/LON/ECT@ECT
cc: Stephen H Douglas/HOU/ECT@ECT, Jeff Blumenthal/HOU/ECT@ECT 
Subject: Instinet Corporation

John:  I hear that you are trying to trade in the name of Enron North America 
Corp. while you sit in London.  Althought both ECT Investments, Inc. and 
Enron North America Corp. have agreements with Instinet Corporation, those 
companies are all U.S. companies without any presence in the U.K. (those 
companies do not pay U.K. taxes!)  I have asked the ENA tax lawyers to review 
the implications of your proposed activity.  I will try to speak with you 
Monday before things go too far.  Please provide an immediate response and 
copy the tax lawyers noted above.  Thanks.  Sara